UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                   WASHINGTON, D.C  20460
   %
                               SEP  2 8  2012
                                                                               OFFICE OF
                                                                             SOLID WASTE AND
                                                                           EMERGENCY RESPONSE
                                                                         OSWER 9200.3-75

MEMORANDUM

SUBJECT:   Transmitta! of the National Strategy to Expand Superfund Optimization Practices from
             Site Assessment to Site Completion
                                         f
FROM:      James E. Wooiford, Director
             Office of Superfund Remediation and Technology Innovation (OSRTI)

TO:         Superfund National Policy Managers (Regions 1-10)

The purpose of this memorandum is to transmit the National Strategy to Expand Superfund Optimization
Practices from Site Assessment to Site Completion (Strategy). The Strategy was jointly developed by
OSRTI, the regions, and representatives from the Office of Research of Development (ORD).
The goals of the Strategy are to expand and formalize optimization practices as an operating business
model for the Superfund remedial program (remedial program) and to fulfill  Action 10 of the  Office of
Solid Waste and Emergency Response Integrated Cleanup Initiative (Id): Opportunities to Provide
Greater Support in Optimizing Cleanup of Superfund Sites. The Strategy envisions the application of
optimization concepts throughout all phases of the remedial pipeline as a normal part of remedial
program activities. To facilitate that process, as part of Contracts 2010, the remedial program  will
modify contracts to allowr for greater opportunities for optimization. Furthermore, it is expected that the
regions review all Fund-lead sites for optimization opportunities by the end of fiscal year 2013. To assist
regional offices with part of this effort, OSRTI will accept nominations for independent  optimization
studies on an ongoing basis. All nominations should be sent to Kathy Yager (yager-kathlcenigepa.gov)
or Dan Powell (powcli .dan(u epa.gov).

If you have any questions or comments please contact Jeff Heimerman at (703)603-7191 or
heimerman.jeff 
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Larry Stanton, OSWER/OEM
Carolyn Hoskinson, OSWER/OUST
David Lloyd, OSWER/OBLR
Reggie Cheatham, OSWER/FFRRO
Nigel Simon, OSWER/OPM
Elliott Gilberg, OECA/OSRE
David Kling, OECA/FFEO
John LaPadula, Region 2
Barnes Johnson, OSWER/OSRT1
Becki Clark, OSWER/OSRTl
Phyllis Anderson, OSWER/OSRTI
Jeff Heimerman, OSWER/OSRTI
Robin Richardson, OSWER/OSRTI
Bruce Means, OSWER/OSRTI
Dan Powell, OSWER/OSRTI
David Cooper, OSWER/OSRTI
Doug Ammon, OSWER/OSRTI
Greg Gervais, OSWER/OSRTI
Barbara McDonough, OSWER/OSRTI
Nancy Jones, OSWER/OSRTI
Lisa Price, Superfund Lead Region Coordinator, Region 6
OSRTI Documents Coordinator

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&EPA
                                           OSWER Directive 9200.3-75
                                                  September 2012
United States                          Office of Solid Waste and Emergency Response
Environmental Protection                        Office of Superfund Remediation and
Agency                                           Technology Innovation
              National Strategy to Expand
       Superfund Optimization Practices from
         Site Assessment to Site Completion
www.epa.gov/superfund/remedytech | www.clu-in.org/optimization | www.epa.gov/superfund/cleanup/postconstruction

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                       NOTICE AND DISCLAIMER

This document presents the U.S. Environmental Protection Agency's National Strategy to
expand and formalize optimization practices from site assessment to site completion as an
operating business model for the Superfund remedial program. The document contains
information designed to be useful for interested stakeholders including governments, the public
and the regulated community. Mention of trade names or commercial products does not
constitute endorsement or recommendation for use. This document was subjected to the
Agency's administrative and expert review and was approved for release as an EPA document.
This document provides topical introductory information rather than guidance and does not
impose legally binding requirements, nor does it confer legal rights, impose legal obligations,
implement any statutory or regulatory provisions or change or substitute for any statutory or
regulatory provisions. EPA recommends that users refer to applicable regulations, policies and
guidance documents regarding selection of cleanup remedies and implementation of cleanup
actions; selected references and additional resources are provided in this document. The Agency
notes that this is a living document that may  be revised periodically without public notice. The
EPA welcomes public comments on this document at any time and will consider those comments
in any future revisions of this document.

This document can be obtained from the EPA's Integrated Cleanup Initiative  (ICI) website at
www.epa.gov/oswer/integratedcleanup.htm,  the EPA's Hazardous Waste Clean Up Information
(CLU-IN) Remediation Optimization website at www.cluin.org/optimization  or the EPA's
Remedy Optimization website at www.epa.gov/superfund/cleanup/postconstruction/
optimize.htm.

For additional information about the EPA's National Optimization Strategy or strategies  for
conducting an optimization review, interested parties may contact Kathy Yager (617-918-8362
or yager.kathleen@epa.gov) or Kirby Biggs  (703-823-3081 or biggs.kirby@epa.gov) of the
EPA's Office of Superfund Remediation and Technology Innovation (OSRTI), Technology
Innovation and Field Services Division (TIFSD).

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                        ACKNOWLEDGEMENTS
The EPA would like to acknowledge and thank the following organizations and individuals who
contributed to the development and review of this document:
EPA National Optimization Steering Committee
• Phyllis Anderson
• David E. Cooper
• Greg Gervais
• Jeff Heimerman
• John LaPadula
• Arnold Layne
• Barbara McDonough
• Bruce Means
• Dan Powell
• Robin Richardson
• Betsy Southerland
• Dana Stalcup
• Cheryl Upton

EPA OSRTI Staff Optimization Team
• Kirby Biggs
• Gerome Burke
• William Dalebout
• Steve Dyment
• Jennifer Edwards
• Silvina Fonseca
• Jennifer Hovis
• Kathy Yager
• Chip Love
EPA National Optimization Workgroup
• JeanBalent
• Frances Costanzi
• Diana Cutt
• Kathy Davies
• Ed Gilbert
• Derrick Golden
• BillHagel
• Joy Jenkins
• Jeff Josephson
• Kira Lynch
• Vincent Malott
• Sandeep Mehta
• Gary Newhart
• Dion Novak
• David Reisman
• Zi Zi Searles
• Nancy Swyers
• Rob Weber
• Kimberly White
• David Wilson
• Kay Wischkaemper
• Bernie Zavala
Appreciation is extended to the EPA Remedial Project Managers (RPM), States, Potentially
Responsible Parties (PRPs) and other stakeholders that have been involved in prior optimization
evaluations and efforts.
                                         11

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  National Strategy to Expand Superfund Optimization Practices
                 from Site Assessment to Site Completion

                                    September 2012

Purpose

This National Strategy (Strategy) institutes changes to Superfund remedial program business
processes to take advantage of newer tools and strategies that promote more effective and
efficient cleanups.1 The Strategy identifies several objectives to achieve verifiably protective site
cleanups faster, cleaner, greener and cheaper. The objectives deploy techniques throughout the
life cycle of site cleanup, including site evaluation, construction and operation and maintenance.
Many of these approaches have been applied for years at a subset of sites under the U.S.
Environmental Protection Agency's management as well as sites managed by other  federal and
state programs. The body of knowledge on applied optimization techniques and their use
throughout the cleanup life cycle is substantial  and growing rapidly. When applied consistently
and systemically to site management, these techniques and the decisions they generate show a
significant return on investment. The U. S. Navy reports a return of greater than 6:1.2 The
Strategy envisions iterative efforts by regions to pursue cost-effective expenditure of Superfund
dollars; lower energy use; reduce carbon footprint; improve remedy protectiveness;  improve
project and site decision making; and accelerate project and site completion.

This Strategy builds on a long history of successful practices and integrates different
optimization technical support efforts. It capitalizes on the benefits of optimization through
multiple processes including: work planning, communicating, training, implementing, measuring
and cost accounting. As part of this Strategy, the Office of Solid Waste and Emergency
Response (OSWER) expects regions to systemically apply optimization concepts throughout all
phases of the remedial pipeline as a normal business practice.

Background

For more than  a decade, the Office of Superfund Remediation and Technology Innovation
(OSRTI) has provided technical support to the EPA regional offices through the use of
independent (third party) optimization reviews at Superfund sites. In addition, OSRTI staff have
worked directly with regional  staff and management to improve the efficiency and cost
effectiveness of our remedial work. To date, OSRTI has conducted more than 120 optimization
reviews at Superfund sites nationwide through Remediation System Evaluation (RSE) and Long-
Term Monitoring Optimization (LTMO) reviews.3 Regions also have performed optimization
1 This Strategy fulfills Action 10 of the Office of Solid Waste and Emergency Response (OSWER) Integrated
Cleanup Initiative (ICI): "Opportunities to Provide Greater Support in Optimizing Cleanup of Superfund Sites"
www.epa.gov/oswer/integratedcleanup.htm. To align with the ICI, this Strategy is intended to be implemented by
the end of Fiscal Year (FY) 2012.

2 Naval Facilities Engineering Command (NAVFAC), "Guidance for Optimizing Remedy Evaluation, Selection, and
Design," UG-2087-ENV, March 9, 2010.

3 For more information on RSE and LTMO, refer to www.cluin.org/optimization.

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reviews at a portion of their sites. Although the majority of optimization technical support has
been applied to Fund-lead Long-Term Response Action (LIRA) sites, OSRTI also has
conducted optimization efforts during remedial investigation/feasibility study (RI/FS), remedial
design (RD) and remedial action (RA); in support of preparing Five-Year Reviews; at Potentially
Responsible Party (PRP) sites; and at state-lead sites.

OSRTI also has provided technical support to regions and other stakeholders in two areas that
are closely related or complementary to optimization - Green Remediation and the Triad
Approach. Green Remediation is  "The practice of considering all environmental effects of
remedy implementation and incorporating options to minimize the environmental footprint of
cleanup activities. "4 The principles of the Triad Approach include systematic project planning,
dynamic work strategies and use of real-time measurement technologies and incorporate many of
the lessons learned from optimization reviews.5 The goals of the Triad Approach are similar to
those of optimization because Triad's goals also support protective and cost-effective remedial
strategies.

The key components of optimization have been used to perform more effectively the activities
necessary to build and refine the conceptual site model (CSM), design and construct more
effective remedies and demonstrate that a site meets cleanup criteria for protectiveness
determinations and ultimately site completion. The benefits derived from these optimization
strategies have included: more cost-effective expenditure of Superfund dollars; lower energy use;
reduced carbon footprint; improved remedy protectiveness; improved project and site decision
making; and acceleration of project and site completion.  Completed optimization reviews at
Superfund sites (predominantly in the post construction phase) have identified over 1,000
recommendations to improve protectiveness; improve the understanding of site conditions; and
identify concrete opportunities to reduce costs associated with components of the remedy.

Other federal agencies, such as the Department of Defense (DoD), have implemented similar
optimization programs to provide independent reviews. The U.S. Air Force and the U.S. Navy
each developed national optimization programs and services addressing sites from the site
assessment (SA) through site completion stages. Since 1999, OSRTI personnel have engaged in
substantive technical and program exchanges with DoD to learn about the structure, processes,
benefits and lessons learned of these optimization programs. OSRTI incorporated various
successful elements from these programs and services into the Strategy, and DoD has in turned
borrowed from the EPA.

Benefits and Approach

OSWER anticipates many benefits from developing and implementing optimization throughout
the Superfund remedial process. These include accelerating achievement of environmental
results contained in the 2011-2015 EPA Strategic Plan (Strategic Plan) and key Government
Performance and Results Act (GPRA) goals which can be downloaded at the following location
4 For more information on Green Remediation, refer to www.cluin.org/greenremediation.

5 For more information on the Triad Approach, refer to www.triadcentral.org.

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(www.epa. gov /ocfo/budget/2010/fy_2010_annual_plan.pdf). A major goal of the Strategy is to
perform optimization reviews as early in the project pipeline as possible, thus realizing
immediate benefits that will carry through a project's life cycle.  In addition, the Strategy
promotes an optimization-oriented focus at subsequent pipeline  stages to ensure that maximum
benefits are achieved wherever possible. Other benefits anticipated include, but are not limited
to:

    •  Achieving better and more cost-effective site characterization;
    •  Improving remedy evaluation and selection;
    •  Improving remedy protectiveness;
    •  Improving alignment of site activities with site remedial  action objectives (RAOs);
    •  Reducing costs;
    •  Providing information to assist with the preparation of Five-Year Reviews;
    •  Proactively identifying potential impediments to site completion;
    •  Accelerating project and site completion;
    •  Addressing community concerns related to site cleanup;
    •  Incorporating newer and greener technologies into site cleanups;
    •  Providing site teams with tools and strategies for more effective site decision making;
    •  Building consensus among site stakeholders;
    •  Providing independent technical input that cross-pollinates expertise among sites;
    •  Improving data and information management practices; and
    •  Improving timeliness,  utility and objectivity of data in decision-makers' hands.


The Strategy unifies previously independent optimization efforts (such as RSE, LTMO, Triad,
Green Remediation, and other ad hoc site consultations) under the singular activity and term
"optimization," which can be used to support decision making throughout the Superfund project
pipeline from SA to site completion (See Figure 1). Furthermore, for those sites in early planning
of the SA stage, the Strategy seeks to utilize optimization lessons learned and practices through
similar technical support mechanisms. The Strategy also encourages activities designed to
facilitate better site characterization, remedy selection and design and remedy construction by
applying various techniques and optimization lessons learned to improve a given  project's scope,
schedule and cost.

Optimization in the context of this Strategy is defined as:

"Efforts at any phase of the removal or remedial response to identify and implement specific actions that
improve the effectiveness and cost-efficiency of that phase. Such actions may also improve the remedy's
protectiveness and long-term implementation which may facilitate progress towards site completion. To
identify these opportunities, regions may use a systematic site review by a team of independent technical
experts, apply techniques or principles from Green Remediation or Triad, or apply other approaches to
identify opportunities for greater efficiency and effectiveness. "6
6 The EPA encourages contractors, states, tribes, the public, and PRPs to propose specific opportunities to improve
protectiveness and efficiency for the Agency to consider.

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Figure 1 depicts the key components of optimization and the remedial pipeline phases at which
optimization can be applied.
Figure 1. Optimization Tools Applied to Cleanup Activities from Site Assessment to Site
Completion
Elements of the National Optimization Strategy

Development of the Strategy involved a collaborative process with the regional Superfund
Programs, OSRTI and the Office of Research and Development (ORD). The Strategy is built on
successful existing strategies, coordination with similar optimization technical support efforts
and expansion of optimization reviews to more sites and all phases of the remedial pipeline. The
following elements form the basis of development and implementation of the Strategy:

   •   Element 1: Planning and Outreach
   •   Element 2: Integration and Training
   •   Element 3: Implementation
   •   Element 4: Measurement and Reporting
Element 1: Planning and Outreach
Element 1 involves a series of planning and outreach efforts to document Strategy goals, apply
optimization to improve community engagement, nominate sites for optimization and coordinate
with related efforts.

       1.1    Establish Strategy goals

       As this Strategy has evolved, it has been important to engage in a planning process and to
       develop quantifiable goals that align with the 2011 - 2015 EPA Strategic Plan. Through
       this planning process, priorities and needs have been identified and incorporated into the
       following overarching goals of the Strategy:

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         •   Incorporate optimization experience and principles in remedial program business
            practices including:
            -  Assessment of site cleanup progress, site technical performance and costs
            -  Regional/OSRTI work planning and reviews
            -  Implementation of acquisition strategies and contracts management practices
         •   Collect, synthesize and share optimization lessons learned;
         •   Apply optimization practices earlier and throughout the remedial pipeline;
         •   Increase the number of optimization reviews supported by OSRTI to 20 to 30
            sites annually; and
         •   Measure optimization outcomes and report results.

     OSRTI and the regions worked collaboratively to implement initial Strategy elements as
     of the end of Fiscal Year (FY) 2012.7  OSWER expects that by the end of FY 2013 the
     regions will review all remaining Fund-lead sites for optimization opportunities and will
     continue to evaluate optimization opportunities at new sites that come under the EPA's
     management.

     Lead: OSRTI and National workgroup

     1.2    Apply optimization as  a means to improve community engagement

     Optimization can be instrumental in providing structure and tools to improve
     communication with communities, local stakeholders, regulatory agencies,  tribes and
     PRPs. Below are a number of examples of how optimization can and has been used to
     facilitate or improve community involvement and communication:

            1.2.1   Triad Approach. Efforts to advance site management strategies that help
            to more fully characterize sites and to increase confidence in the understanding of
            the extent, location and behavior of contamination can help communicate site
            conditions and progress to stakeholders. See www.triadcentral.org for more
            information.

            1.2.2   Remediation System Evaluations (RSE) and Long-Term Monitoring
            Optimization (LTMO). The use of optimization practices to address stakeholder
            concerns and provide information on the protectiveness and efficacy of remedies
            may provide more confidence to  communities that remedies are and remain
            protective. See www.cluin.org/optimization for more information.

            1.2.3   Green Remediation. Reducing the environmental footprint of remedies
            through environmental footprint reviews helps stakeholders understand the
            potential effects of remedies on their environment and project teams to understand
            and minimize those effects. See www.cluin.org/greenremediation for more
            information.
Optimization reviews are being conducted concurrently with the development and implementation of the Strategy.

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       1.2.4  Knowledge Transfer. Current information resources and infrastructure,
       provided through www.epa.gov/superfund and www.cluin.org and the
       Technology Innovation and Field Services Division's (TIFSD) Internet seminars,
       provide a great deal of readily available and accessible information to
       stakeholders. In addition, OSRTI, regions and ORD have subject matter experts
       who can assist regions with community meetings related to site characterization
       and cleanup.

       1.2.5  Training.  OSRTFs CERCLA Education Center (CEC) and the
       Environmental  Response Training Program (ERTP) support desired training for
       the EPA and state regulators, tribes and other government stakeholders, and could
       emphasize (and, if necessary, strengthen or update) the stakeholder outreach
       curricula in "process" classes. See www.trainex.org for more information.

OSRTI Lead Divisions: Assessment and Remediation Division (ARD)/TIFSD

1.3    Identify projects and sites for optimization

A collaborative process between OSRTI and the regions is being used currently to
identify sites or  site projects that would benefit from an optimization review. Regions
determine which sites may warrant an independent optimization review and, as
applicable, request optimization support from the headquarters (HQ) team. Support can
be provided by OSRTI, regional or ORD resources. The following are examples of
general criteria that suggest an optimization review may be beneficial:

   •   Desire to accelerate or improve effectiveness of the remedial process;
   •   Opportunities to reduce cumulative project costs;
   •   Options for handling funding constraints;
   •   Transition of projects between entities (for example, before a Fund-lead site
       transfers to a state);
   •   Achieving Environmental Indicators (such as Human Exposure Under Control
       (HEUC) and Groundwater Migration Under Control (GMUC));
   •   Supporting an upcoming Five-Year Review; and
   •   Addressing Five-Year Review recommendations.

Other government stakeholders (such as states,  tribes and local governments) and
communities may initiate a request for optimization technical support through their
respective EPA regions. Based on regional determination and available resources,
OSRTI, ORD and regions may provide the requested technical support.

In FY 2013, all regions are expected to review their active  Fund-lead sites to identify
candidates for potential optimization reviews. This requirement will be outlined in a
memorandum to the regions by the end of November 2012. This effort will also be
discussed in all OSRTI/Regional work planning meetings.

Leads: OSRTI and Regions

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       1.4    Coordinate with complementary technical support efforts

       Existing optimization efforts support established remedial program goals. Optimization
       reviews support the National Remedy Review Board (NRRB), Contaminated Sediments
       Technical Advisory Group (CSTAG), Value Engineering (VE), program measures such
       as construction completion, operational and functional, Site-Wide Ready for Anticipated
       Use (SWRAU), HEUC, GMUC and other program requirements such as Five-Year
       Reviews and LTRA transfer.

       This element also involves coordinating with key related EPA workgroups and proposing
       strategies to connect optimization and avoid conflicts with their efforts. Key workgroups
       include the subgroups of the Technical Review Workgroup (TRW), Groundwater Forum,
       Engineering Forum, Federal Facilities Forum and the National Association of Remedial
       Project Managers (NARPM).

       OSRTI Lead Division: ARD/Resource Management Division (RMD)
Element 2: Integration and Training

Efforts are continuing to fully integrate optimization into program operations through
supplementing existing guidance documents (as appropriate); evaluating current incentives for
optimization; incorporating optimization language into contracts; and developing a more robust
training program.

       2.1     Create  technical resources to supplement existing guidance and policy, and
              address optimization in new guidance

       OSRTI is organizing existing optimization-related resources to describe how
       optimization principles, practices and techniques can be utilized with current
       programmatic guidance, as needed. Existing guidance may be supplemented by
       directives, technical bulletins, fact sheets and other materials to explain how optimization
       applies at various stages of cleanup. Furthermore, OSRTI will prepare additional
       technical resource material (such as training courses, fact sheets and an updated resource
       center website) as appropriate, based on new findings and lessons learned as the  Strategy
       is implemented. These enhancements to guidance are intended to enable project teams to
       integrate improved methods and strategies for cleanup learned from previous
       optimization studies into site characterization, remedy selection and remedial design.
       OSRTI also is developing  standard operating procedures such as project engagement
       forms, checklists and documentation to facilitate the scoping and conduct of optimization
       reviews (see Element 3.3 for more information).

       OSRTI Lead Divisions: ARD/TIFSD

       2.2     Adopt lessons learned into business practices

       On a routine basis, optimization lessons learned will be collected, summarized and
       discussed by OSRTI and regional program and project staff to determine how our
       business practices (including contracting) can benefit from these lessons learned. In

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addition, several program directives (for example, directives related to VE) include
contract-specific requirements that could be leveraged.

As part of Contracts 2010 implementation
(www.epa.gov/oswer/docs/contracts_2010_strategy_report.pdf), the remedial program
will be refining contracts to allow for greater opportunities for optimization. Specifically,
OSRTI, working with the Office of Acquisition Management (OAM), will work to add
language to task orders, work assignments and contract vehicles to promote optimization.
Such language could include incentives regarding performance proposals. Project-
specific Statements of Work may likely be the best tool to incentivize or direct
contractors to gather and analyze data and trends to evaluate site progress toward the
RAOs. Identifying and utilizing these best management practices across sites and regions
may be one of the most important objectives of the Strategy.

OSRTI Lead Divisions: RMD/TIFSD/ARD

2.3    Formalize an optimization training program

OSRTI has actively  promoted optimization knowledge transfer since optimization
activities commenced in the late 1990's. To date, OSRTI has sponsored national
conferences on optimization, in-person training events and Internet-based training  events;
developed many technical documents; presented optimization findings at numerous
national conferences; and provided site-specific support. OSRTI has specifically targeted
EPA Remedial Project Managers (RPM) and technical staff by participating in and
developing training courses for NARPM training and Technical Support Project (TSP)
meetings. However, this training was developed and offered on an ad hoc basis and all
facets of optimization were not consolidated into a formal, unified training program. The
goal of the training sub-element is to review training needs associated with the Strategy,
consolidate existing training material, develop new training as needed, deliver training
and ensure that appropriate project and program managers have access to the training
material on an ongoing basis (such as via archived training material, CEC and ERTP).

Additional technology transfer and training will be necessary as the Strategy is
implemented. The substantial resources already developed are being assembled into a
comprehensive optimization training program. Optimization training, supplements to
guidance and other technical resources could also be assembled into a unified, organized
web presence so that the EPA staff, state personnel, tribal members and contractors can
conveniently access technical, policy and training information as needed. Training will
provide a number of benefits, including, but not limited to:

    •   Increased knowledge of optimization practices and tools for all participants;
    •   National consistency in the quality of,  approach to and outcomes of optimization
       efforts;
    •   An anticipated increase in the number of sites that are recommended for
       optimization; and
    •   Expansion of region-led optimization efforts.

OSRTI Lead Division: TIFSD/ARD

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Element 3: Implementation
Element 3 involves implementing the Strategy based on the goals established through the
planning process. Implementation involves conducting optimization reviews at all stages of the
project pipeline beginning with SA; incorporating Triad, Green Remediation and other best
practices; providing access to a pool of qualified optimization contractors; developing the
capabilities of regions and other stakeholders; and advancing the application of innovative
optimization strategies.

       3.1    Conduct optimization reviews at all stages of the project pipeline beginning
             with site assessment

       The optimization program is being implemented based on the strategic goals identified in
       Section  1. The remedial program has established a target goal of OSRTI providing
       independent optimization reviews to 20 to 30 sites per year for 3 years,  after which a joint
       OSRTI/regional review of the optimization program is proposed to determine whether the
       number  of sites should be maintained, increased or decreased. The actual number of sites
       optimized in any year, however, relies upon annual budget appropriations.

       3.2    Expand optimization to earlier project pipeline stages and incorporate Triad,
             Green Remediation and other best practices

       Although optimization has historically been applied primarily to sites with operating
       remedies, through this Strategy OSRTI is expanding optimization  to sites earlier in the
       Superfund project pipeline, including SA, remedial investigation (RI), feasibility study
       (FS) and RD.

       Optimization at these cleanup stages may consist of equivalent independent reviews that
       employ  strategies such as the Triad Approach and will be informed by lessons learned
       from historical and ongoing optimization reviews. Some sites in the early phases of work
       may not have sufficient information to complete independent optimization reviews but
       instead can receive technical assistance in applying the latest analytical  methods,
       sampling tools and project management strategies. The Strategy encourages the
       application of lessons learned from optimization reviews to all of these  Superfund project
       pipeline activities. Furthermore, Green Remediation environmental footprint evaluations
       should be integrated into optimization reviews, where appropriate, to identify
       opportunities to further optimize site activities, while reducing the impact of
       characterization and remedial efforts on the environment. Finally,  optimization efforts
       should integrate best practices from across the remedial  program.

       3.3    Independent party optimization review steps

       After a site is identified for optimization, an optimization team is assembled consisting of
       independent experts with relevant qualifications tailored for each site's  needs.  Efforts are
       made to inform and include all stakeholders (such as regional management, site owners,
       PRPs, states, tribes, local governments, communities and others),  as they may  have a
       vested interest in optimizing site performance. Regional management will be informed
       regularly on the status of an optimization project when OSRTI is involved and will
       receive copies of draft final optimization review reports. With completion of each review

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       there will be a senior management briefing to discuss the results, any potential
       impediments to implementing recommendations and the path forward for the site.

       To initiate an independent party optimization review, key site data are identified and
       transferred to the optimization team for evaluation. Pipeline stage and the quantity and
       quality of data will be significant factors in establishing the nature and goals of the
       review. Optimization reviews typically are conducted through a series of conference calls
       or web conferences and a site visit (as appropriate) to collect and evaluate appropriate site
       data. For optimization reviews performed at some sites, follow-on technical support may
       be appropriate to fill gaps necessary to fully evaluate site or project conditions and to
       further develop strategies for implementing the recommendations. Numerous existing
       technical documents describe the steps involved in an optimization review.8

       OSRTI has also developed several new documents to establish a consistent and
       standardized approached to implementing optimization reviews. These documents will be
       available in electronic format at www.cluin.org/optimization and include:

          •   An optimization standard operating procedure;
          •   An optimization primer and overview;
          •   An optimization engagement form;
          •   Management notification emails; and
          •   A template optimization report.

       OSRTI Lead Divisions: TIFSD/ARD

       3.4     Provide access to a pool of qualified, independent contractors

       OSRTI has access to technical experts who perform the majority of EPA optimization
       reviews and are currently available to perform optimization reviews. Experts  currently
       available include OSRTI staff, OSRTI mission support contractors, Argonne National
       Laboratory and the U.S. Army Corps of Engineers (USAGE). Regions also have used
       Remedial Action Contract (RAC) contractors to perform  optimization reviews. OSRTI's
       experience confirms that it is critical to use only highly qualified technical experts.
       Optimization involves the synthesis and analysis of a significant quantity of data in a
       limited time frame and budget. To accomplish optimization objectives, contractors must
       have demonstrated qualifications and the capacity to accomplish these goals on highly
       challenging, unique and complex sites across the country.

       As part of the Strategy, in the future it may be beneficial to expand the pool of experts
       available to OSRTI and the regions to perform optimization reviews. Regions also can
       perform optimization reviews through regional acquisition mechanisms (for example,
       RAC and USAGE) or through "buy in" to existing OSRTI contracting and Inter-agency
       Agreement mechanisms. A variety of national and regional contracting strategies are
8 For more information on how to conduct optimization reviews refer to www.cluin.org/optimization or
www.frtr. gov/optimization.
                                           10

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currently being evaluated to ensure OSRTI and regional access to optimization review
resources.

OSRTI Lead Divisions: TIFSD/ARD/RMD

3.5    Develop regional optimization capabilities

To fully integrate optimization into the remedial program, regional offices have been
involved in planning and implementing optimization at all stages of the remedial process.
Involving regional offices is helping to establish an expanded pool of EPA staff
knowledgeable of optimization approaches, benefits and complications. Direct
involvement of regional staff is also essential to the selection of sites for optimization,
subsequent oversight of optimization reviews and implementation of recommendations.
Each region has identified an "Optimization Liaison" who serves as the primary point of
contact for the region for  selecting sites, assisting with completing optimization studies
and interfacing with OSRTI on all aspects of implementing the Strategy in that region.

Regions worked with OSRTI to develop and finalize the Strategy and continue to identify
and select high-priority sites; oversee optimization reviews; review optimization reports;
track progress toward implementation; and report results. OSRTI assists in site
prioritization and selection, as appropriate, provides access to independent optimization
contractors, collects and analyzes reported results, and measures outcomes. OSRTI also
will assist regions in assessing funding sources for implementation of optimization
recommendations at Fund-lead sites. As needed and as resources will allow, OSRTI will
provide technical support during implementation, irrespective of a  site's funding source.

OSRTI will continue managing contractor site  optimization review efforts until at least
the end of FY 2013. Over time, regions are anticipated to become increasingly involved
in performing optimization studies. Continued  use of OSRTI's current optimization
technical support strategy and resources will help ensure optimization reviews are
performed with consistency by contractors who are qualified  and independent, while also
reducing the contracting burden to the regions. Future contracting scenarios could include
contracts managed directly by OSRTI with the regions serving as task managers; regions
utilizing region-specific contracts; or regions using federal resources via interagency
agreements. Regardless of the contracting approach, it is essential to the optimization
process that review teams be composed of qualified experts who are independent from
the site contractor. Contract language, including statements of work (SOW), will be
established for regional use in procuring and managing site optimization contracts and
projects.  An important component of developing regional optimization capabilities
involves training for regional staff, contractors and other EPA stakeholders. Please
reference section 2.3 of this document for more information on formalizing an
optimization training program.

Leads: TISFD/RMD/Regions/OAM

3.6    Develop other stakeholders' capabilities

All stakeholders, including state project managers, should be included at the outset of
optimization reviews, during implementation and during follow-up tracking. It will be
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       necessary, therefore, to assist some states, tribes, communities and other stakeholders
       with development of their optimization capabilities, through training as indicated in
       Element 2.3 and participation in optimization efforts as indicated in Element 3.1.

       OSRTI Lead Divisions: TIFSD/ARD

       3.7    Advance application of innovative optimization strategies

       OSRTI will maintain involvement in innovations in the optimization arena by continuing
       to participate in ongoing research projects (for example, ORD, DoD's Strategic
       Environmental Research and Development Program [SERDP] and Environmental
       Security Technology Certification Program [ESTCP], National Institute of
       Environmental Health Sciences [NIEHS] Superfund Research Program, Interstate
       Technology and Regulatory Council [ITRC], national laboratories and universities),
       performing general tracking of developments by other agencies or the private sector, and
       encouraging and deploying innovative approaches at Superfund sites.

       OSRTI Lead Division: TIFSD
Element 4: Measurement and Reporting

Element 4 involves tracking progress of optimization, measuring outcomes and accounting for
related costs.

       4.1    Track implementation of recommendations

       Two critical components of a successful optimization program include tracking
       implementation progress and reporting results. Experience has shown that with tracking
       and reporting, optimization recommendations are more likely to be implemented and
       benefits realized. Because optimization often results in follow-on work, RPMs will
       benefit from ongoing involvement by the optimization team to clarify report
       recommendations, answer questions and identify additional technical support needs.

       A process to measure the outcomes of the Strategy is being developed to effectively track
       implementation of recommendations. Metrics being considered include, but are not
       limited to, protection of human health and the environment; assistance with achieving
       program measures (such as operational and functional, acceleration of site completion,
       and special initiatives such as Green Remediation); and cost impacts  (for example,
       potential cost savings identified, capital costs, cost avoidance, and cost  savings realized).
       At a minimum, the following elements may be considered for each optimization study:

          •  Status of each optimization recommendation (completed, in progress, declined);
          •  Cost impacts of each optimization recommendation (capital costs, cost avoidance,
             cost savings);
          •  Benefits that resulted from implementation;
          •  Obstacles encountered during implementation; and
          •  Other metrics that allow for quantifying optimization results.
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       To support recommendations and results tracking, a platform for managing, tracking and
       reporting optimization information is being developed. This platform will facilitate
       analysis of program effectiveness. With the support of regions, OSRTI will maintain the
       information tracking system.

       OSRTI Lead Divisions: ARD/TIFSD/RMD

       4.2    Measure optimization outcomes and report results

       Development and implementation of the Strategy and site-specific and program-wide
       results are anticipated to be summarized and reported regularly. An annual report
       prepared by OSRTI is proposed for internal and public distribution. The document may
       include a summary of Strategy goals; a summary of regional optimization review efforts;
       a site-by-site summary of optimization results;  quantified optimization outcomes; lessons
       learned; and suggestions for improvement.

       OSRTI Lead Divisions: ARD/TIFSD

       4.3    Monitor cost accounting

       Through program measurement and tracking described above, cost expenditures  and
       identified savings will be reported on a regular basis. Cost accounting information can be
       used to determine whether changes are necessary to ensure that optimization program
       goals are achieved in the anticipated timeframe. Costs incurred and deliverables prepared
       by support contractors will be closely tracked to ensure that contract requirements are
       achieved at reasonable cost to the government.

       Leads: RMD/Office of the Chief Financial Officer (OCFO)/OAM
Implementation Schedule

The Strategy proposes to expand optimization to more sites nationwide, with the following three
primary milestones:

   •   Start implementation - second quarter, FY 2011
   •   Finalize Strategy - end of FY 2012
   •   Implement Full Strategy - by beginning of F Y 2013
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                      ATTACHMENT A - LIST of ACRONYMS

Acronym    Definition

 ARD       Assessment and Remediation Division
 CEC       CERCLA Education Center
 CERCLA   Comprehensive Environmental Response, Compensation, and Liability Act
 CSM       Conceptual Site Model
 CSTAG    Contaminated Sediments Technical Advisory Group
 DoD       Department of Defense
 EPA       U.S. Environmental Protection Agency
 ERTP      Environmental Response Training Program
 ESTCP     Environmental Security Technology Certification Program
 FS         Feasibility Study
 FY         Fiscal Year
 GMUC     Groundwater Migration Under Control
 GPRA      Government Performance and Results Act
 HEUC      Human Exposure Under Control
 HQ        Headquarters
 ICI         Integrated Cleanup Initiative
 ITRC       Interstate Technology and Regulatory Council
 LTMO      Long Term Monitoring Optimization
 LTRA      Long Term Response Action
 NARPM    National Association of Remedial Project Managers
 NIEHS     National Institute of Environmental Health Sciences
 OAM       Office of Acquisition Management
 OCFO      Office of the Chief Financial Officer
 ORD       Office of Research and Development
 OSRTI     Office of Superfund Remediation and Technology Innovation
 OSWER    Office of Solid Waste and Emergency Response
 PRP       Potentially Responsible Party
 RA        Remedial Action
 RAC       Remedial Action Contract
 RAO       Remedial Action Objective
 RD        Remedial Design
 RI         Remedial Investigation
 RI/FS       Remedial Investigation/Feasibility Study
 RMD       Resource Management Division
 RPM       Remedial Project Manager
 RSE       Remediation System Evaluation
 SA         Site Assessment
 SERDP     Strategic Environmental Research and Development Program
 SOW       Statement of Work
 SWRAU    Site-Wide Ready for Anticipated Use
 TIFSD      Technology Innovation and Field Services Division
 TRW       Technical Review Workgroup
 TSP       Technical Support Project
 USAGE    U.S. Army Corps of Engineers
 VE         Value Engineering
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